ML20234E945
| ML20234E945 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 09/17/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Campbell G ARKANSAS POWER & LIGHT CO. |
| References | |
| NUDOCS 8709220575 | |
| Download: ML20234E945 (2) | |
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I In Reply Refer To:
Dockets: 50-313/87-18
~50-368/87-18 Arkansas Power & Light Company ATTN:. Mr. Gene Campbell Vice President, Nuclear Operations
.P. 0.- Box 551
' Little Rock, Arkansas 72203 Gentlemen:
l Thank you for your. letters of August 14 and August 28, 1987, in. response
~
L to our letter 'and Notice of Violation dated July ~ 16,1987. - We have reviewed l
your reply and find it responsive to the concerns raised in our Notice of 1-Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and
.will be maintained.
i Sincerely, cg;\\gn\\ W h
- (pma L B;l J. E. Gagliardo-Chief Reactor Projects Branch cc
J. M. Levine, Director Site Nuclear Operations j
Arkansas Nuclear One P. 0. Box 608 Russellville, Arkansas-72801 Arkansas Radiation Control Program Director i
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ARKANSAS POWER & LIGHT COMPANY August 14, 1987 BCAN088701 Mr. J. E. Gagliardo, Chief Reactor Projects Branch U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011
SUBJECT:
Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313/50-368 License No. DPR-51 and NPF-6 Response to Inspection Report 50-313/87-18 and 50-368/87-18
Dear Mr. Gagliardo:
Pursuant to the provisions of 10CFR2.201, a response to the violation identified in the subject inspection report is submitted.
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evine xecutive Director Nuclear Operations JML:PLM:djm enciosure I
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Enclosure August 14, 1987
~Page 2 Notice of Violation Technical Specification 6.8.1 requires, in part, that written procedures shall be_ established, implemented, and maintained t
covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, November 1972.
Section I.4 of this Appendix includes procedures for exercising equipment which is normally idle, but which must operate when required.
j Procedure 1106.06, Supplement III, Emergency Feedwater Valve Stroke Testing, has been established in accordance with this Technical Specification.
A note following Step 2.39 of this procedure requires that, "A dedicated operator must remain in the vicinity of CV-2870 when it is open to manually close the valve in the event it does not close electrically".
~
Contrary to the above, on June 16, 1987, a dedicated operator was not stationed at CV-2870 as required when cycling this valve during the performance of Procedure 1106.06, Supplement III.
This is a Severity Level IV violation.
(Supplement 1)(313/8718-01)
Response to Violation 313/8718-01 (1) The reason for the violation if admitted:
AP&L agrees that a violation of the requirements of procedure 1106.06, Supplement III, occurred in that a dedicated operator was not posted when opening valve CV-2870, emergency feedwater pump P7A test recirculation isolation valve.
Valve CV-2870 is normally closed, but when performing pump i
i testing or valve stoke testing, the valve is opened.
If an emergency feedwater actuation were to occur during this testing, the safety function of CV-2870 would be to close.
During the previous refueling outage, a valve testing program was performed to address NRC Bulletin 85-03, Motor Operated Valve Common Mode Failure During Plant Transients Due to Improper Switch Settings.
This testing employed M0 VATS equipment and was designed, in part, to identify valve actuators that could not operate against a maximum expected differential pressure.
The actuator for Valve CV-2870, in the "as-found" condition, did not develop established thrust values for the maximum expected differential pressure across this valve.
As a result, the l
actuator was replaced with a higher capacity actuator.
l l-During this replacement, it was necessary to install a non-Q motor in the actuator as a Q motor was not available.
In order t
to assure that the actuator performed its safety' function
Enclosure August 14, 1987 Page 3 if called upon during testing, a caution card was placed on I
the valve handswitch in the Control Room and changes to procedure' 1106.06 added requirements to post a dedicated operator at the valve when it is opened to ensure proper closure.
The changes affected 1106.06, Supplement II, Steam Driven EFW Pump Test (Monthly), and Supplement III, EFW Valve Stroke Testing.
The changes were to remain in effect until the non-Q motor was replaced with a Q motor.
The original procedure changes were added to the procedure using a temporary change form which was handwritten.
The writer j
made use of a note to direct stationing a dedicated operator at l
valve CV-2870 when it is open.
This was not in accorjance with
)
the Operations Procedure Writers Guide for the use of a note.
The directions would have been more appropriate as instructional steps.
Additionally, the note was placed following. opening and closing CV-2870 rather than preceding these instructions as would have been in accordance with the writers guide for use of 1
a note.
Due to the poor placement of the note, the operator performing l
the valve stroke testing failed to recognize the note as a requirement relating to opening CV-2870.
Instead, he interpreted the note to mean that only if the valve failed electrically was an operator required to be posted at the valve.
In addition, he disregarded the handswitch caution card.
(2) The corrective steps that have been taken and the results achieved:
Upon realizing the error, an operator was dispatched to valve CV-2870 to verify closure of the valve as required by the procedure.
The valve functioned properly.
The operator performing the valve stroke testing was reprimanded for his mistakes.
To improve the procedure structure which contributed to the performance error, a temporary change was written which relocated the note to precede the steps for valve CV-2870.
The change also added specific steps to the procedJre which require stationing an operator at the valve before opening the valve and releasing the
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operator after closing the valve.
(3) The corrective steps that wi#1 be taken to avoid further violations:
The Q motor will be installed in the CV-2870 actuator and the M0 VATS testing will be completed.
This will eliminate the need for posting an operator at the valve, as the valve will then be in the correct design configuration.
The requirements now included in procedure 1106.06 will be deleted when the motor replacement is complete.
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Enclosure August 14, 1987 Page 4.
(4) The date when full compliance will be-achieved:
Full compliance was achieved upon verification of closure of CV-2870.
This occurred the day of the testing, June 16, 1987.
The motor is scheduled to be replaced as soon as plant conditions allow.
This work should be complete, at the latest, by the end of the mid-cycle outage currently scheduled for late October, 1987.
Following motor replacement and M0 VATS testing, procedure 1106.06 will be revised to delete the requirements instituted for valve CV-2870 while.in a condition outside the normal design configuration.
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